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22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) The obligation of a purchaser under a conditional sales agreement generally will be included in its capital only where such obligation has been outstanding for more than 365 days, unless the obligation is evidenced by the issuance by it to the vendor of a note. ...

22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) A lease obligation reflected as an asset on the balance sheet of a lessor corporation is not eligible for an investment allowance as a loan or advance. ...

11 October 2013 Internal T.I. 2013-0475761I7- Deadline for filing a waiver of tax credit – ORDTC-- summary under Subsection 152(4) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4) waiver of credit after return due date A corporation filed its original 2011 T2 return somewhat after the filing due date, and then requested an adjustment to amend the return by waiving the full amount of the previously-claimed Ontario Research and Development Tax Credit. ...

14 March 2013 Internal T.I. 2012-0451131I7- Trustee's Rights & Obligations under the Act-- summary under Subsection 150(3) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(3) Although s. 22 of the Bankruptcy and Insolvency Act requires a trustee to file only the return for the taxation year before the year of bankruptcy, and the return for the year of bankruptcy, s. 164(2.01) of the Act forbids the Minister from paying a refund where returns have not been filed under the Act. ...

4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate-- summary under Subsection 90(6) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(6) inclusion not dependent of maintenance of creditor affiliate status Where a non-resident subsidiary (FA) of Canco has made a loan to a non-resident subsidiary (SisterCo) of Canco’s non-resident parent (Foreign Parent), CRA considers that it is irrelevant that FA has ceased to be a creditor affiliate of SisterCo two years later, as a result of the sale by Canco of FA to Foreign Parent, so that s. 90(6) could still apply to include the loan’s amount in Canco’ income. ...

17 March 1997 Internal T.I. 9631007- INTERACTION OF 85(1) & 110.6(19)-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) The benefit of making an election under s. 110.6(19) in respect of an eligible capital property or a depreciable property effectively will be lost if the property is transferred on a rollover basis to a corporation. ...

14 July 1994 Internal T.I. 9407377- NON-RESIDENT PARTNER & 216 ELECTION (7558-3)-- summary under Regulation 805 Summary Under Tax Topics- Income Tax Regulations- Regulation 805 If a partnership is determined to be carrying on business in Canada, there will be no Part XIII tax liability in respect of rent paid to the partnership on the presumption that a non-resident partner is considered to be carrying on business through a permanent establishment in Canada. ...

17 December 1996 Internal T.I. 9625727- REMARRIAGE CLAUSE & DEF'N OF SPOUSAL TRUST-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) Where a will provided that the widow was entitled to receive the income of the estate but that her entitlement was "to be terminated upon her death or remarriage", and it is proposed that a court order be obtained removing the remarriage clause, RC will accept that the property of the estate vested indefeasibly in the spouse's trust within the 36-month period only if the court order is made within 36 months of the date of death. ...

& Section 116116(5)-- summary under Subsection 49(3) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(3) S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...

2 October 2002 Internal T.I. 2002-0135807 F- Lumpsum Somme Forfaitaire Reg 102 / 103-- summary under Paragraph 103(4)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 103- Subsection 103(4)- Paragraph 103(4)(c) withholding on retiring allowance paid in periodic instalments determined under Reg. 102(1) Where a retiring allowance of $30,000 was paid in 30 equal weekly payments of $1,000 to a Quebec employee, the Directorate determined that the rate of withholding would be determined under Reg. 102(1) on the basis of being periodic payments of $1,000 rather than pursuant to Reg. 103(4)(c)(i) as a lump sum payment over $15,000. ...